Contents

How We Collect, Disclose, and Use Personal Data

Is Stripe acting as a data controller or a data processor?

The answer is both.

The “data controller” is the entity which determines the purposes and means of the data processing taking place. The “data processor” is an entity acting on behalf and under the instructions of a controller in processing personal data.

Stripe is a data controller when it determines the purposes and means of the processing taking place. These data processing activities include (1) providing the Stripe products and services, (2) monitoring, preventing and detecting fraudulent payment transactions and other fraudulent activity on the Stripe platform, (3) complying with legal or regulatory obligations applicable to the financial sector to which Stripe is subject, and (4) analyzing, developing and improving Stripe’s products and services. Please see this Privacy Center article for more information on Stripe’s controller activities.

Stripe is a data processor where it is facilitating payment transactions on behalf of and at the direction of a Business User. Our Business Users direct us to take payment from cardholders / End Customers.

Stripe is considered a processor when directed to process payments (i.e., Stripe receives instructions about whom to pay, how much to pay, when to pay).

As a platform provider, we need to ensure consistency across our platform, and that includes consistency with respect to the commitments that we give about how we operate our platform. We contract with all of our Business Users (including some of the world’s largest companies) on this basis.

Which Stripe entities are involved?

For most of our services, it is either Stripe, Inc., the US parent company operating under US law, or Stripe Payments Europe, Limited (“SPEL”), an Irish company operating under Irish law, the data controller responsible for Personal Data collected and processed in relation to Stripe Services.

The Stripe entity responsible for your data will depend on your location, the product or service you use with us and whether Stripe is acting as a controller and/or data processor.

If you are located in the European Economic Area (“EEA”), Switzerland or the United Kingdom, SPEL is the primary entity responsible for the processing of your personal data. Some of the payment processing services offered by SPEL are services that may be only provided for by an authorised payment services provider or electronic money institution. In this case, SPEL and the Stripe local regulated entity (defined as those who are licensed, authorized or registered by a Local Regulatory Authority) will act as joint controllers of your Personal Data.

Please see our table below for more information on who is your controller in these jurisdictions:

Stripe affiliates also provide local support services in certain countries where Stripe operates. These entities act as data processors on behalf of Stripe, Inc. or SPEL, depending on the jurisdiction. You will find the most up-to-date list of the Stripe affiliates on this page.

For certain products, Stripe may act as an independent controller (e.g. Stripe Capital), a data processor or both (e.g. Stripe Identity). Please see the Privacy Center article for each specific product for more information.

What are your data controller activities?

• Providing the Stripe products and services to Business Users and End Users, including determining the third parties (banks and payment method providers) to be utilized;
• Monitoring, preventing and detecting fraudulent payment transactions and other fraudulent activity on the Stripe platform;
• Complying with legal or regulatory obligations applicable to the financial sector to which Stripe is subject, including applicable anti-money laundering screening and compliance with know-your-customer obligations; and
• Analyzing, developing and improving Stripe’s products and services.

As a Stripe User and as a data controller, what does GDPR mean for me?

Take a look at our General Data Protection Regulation (“GDPR”) Guide.

In addition, as a data controller, Business Users are responsible for the relationship with the data subject (i.e., your End Customer). You may instruct a third party (like Stripe) to process the data, but it is your job to set the purpose (or objectives) and legal basis for the processing.

The GDPR requires data controllers to use third parties who agree to abide by certain contractual terms. To be sure of this, the data controller must have Data Processing Agreements (“DPAs”) with each third party. Our DPA has been designed to serve this purpose for you; it is strongly aligned with payment transactions, so it should establish that you are compliant with GDPR from a payments perspective.

Who are Stripe’s sub-processors and how are they vetted?

Please see our service providers page where we have a list of our most common sub-processors, service providers and affiliates. Stripe identifies, evaluates, and engages sub-processors through our vendor management program. We enter into a contract with each sub-processor prior to sharing data with the sub-processor, and each contract contains terms that provide for monitoring and audit. In addition, all potential vendors are vetted and approved through Stripe’s security review process before we begin using their services.

From where does Stripe collect information used for fraud prevention and security purposes?

To prevent fraud and strengthen our security, we may collect information from Business Users, End Customers, End Users, financial parties, and in some cases third parties. For example, we collect and analyze information that helps us identify bad actors and bots, including both transactional data (such as amount, customer shipping address, date, and so on) and advanced fraud detection signals (device and activity signals). Learn more.

Stripe also receives information from third parties to prevent and respond to security incidents, and for protecting against other fraudulent activity. For example, we may receive information from third parties about IP addresses that malicious actors have compromised.

I heard that Stripe is collecting additional information about my account from a third party and/or my other Stripe account. Why is Stripe collecting this information?

Stripe may collect additional information about your account to allow Stripe and its financial partners to detect fraud and/or fulfill financial compliance requirements. These requirements come from our financial partners or regulatory obligations and are intended to prevent abuse of the financial system. Examples of missing data fields include your address, phone number, social security number, date of birth, employer identification number, or website URL. Stripe may be able to fill in some of this information by leveraging data we have collected from one of your other Stripe accounts or by obtaining data from a third party. We will show Business Users the information that we are associating with their account on your dashboard, and Business Users may update or correct that information via your dashboard. Please see Stripe’s Privacy Policy for additional information.

Does Stripe sell my personal information under the CCPA?

Stripe does not sell personal information. As such, we do not have actual knowledge that we sell personal information of minors under 16 years of age. For California residents, the California Consumer Privacy Act (“CCPA”) defines “selling” personal information to include providing it to a third party in exchange for money or valuable consideration. See Cal. Civ. Code § 1798.140(t)(1).

For Shine the Light law (Cal. Civ Code § 1798.83) purposes, Stripe does not share personal data of California customers to third parties for their direct marketing purposes, as defined by this law.

The table below discloses the categories of personal information about California consumers that we collect and disclose for a business purpose.

In addition to its sub-processors, what other third parties does Stripe share information with?

When we work with service providers in our capacity as a data processor for our Business Users’ and End Users’ personal data, the GDPR calls these third-party service providers a sub-processor. Sub-processors are service providers who have or potentially will have access to or process personal data on behalf of Stripe. These third parties are disclosed on our Stripe Service Providers List.

In addition to Stripe’s sub-processors, we may also share Business Users’ onboarding data and payment instrument information with third party business partners when this is necessary to provide our services to our Business Users. We do so, for example, for the purposes of offering payment processing services to our Business Users or facilitating payment settlements.

Third parties to whom we may disclose personal data for this purpose are banks, payment method providers and payment processors, including, but not limited to, the following entities:

• American Express Payment Services Limited and American Express Payments Europe S.L.
• Banking Circle S.A.
• Barclays Bank PLC
• Credit Mutuel Arkea and Arkea Banking Services
• Currence iDEAL B.V.
• Klarna AB
• Mastercard Europe S.A.
• Polski Standard Płatności
• PPRO Financial Ltd.
• Swisscard AECS GmbH
• Visa Europe Limited

The data shared with payment method providers will depend on the payment method(s) enabled on the Business User’s account.

In addition, Stripe shares personal data as we believe necessary to, among other things, protect Stripe’s services, rights, privacy, safety and property of Stripe, our users or others. For example, to protect our services, Stripe may receive or disclose information about IP addresses that malicious actors have compromised.

Transfer

Stripe will pass on personal data to affiliates and service providers or sub-processors, if deemed strictly necessary to carry out contractual obligations or for the data to be processed. Depending on the enabled payment method(s), data may be transferred to the jurisdiction(s) of the respective payment method(s). Before we engage any third party, we perform due diligence, including a vendor security assessment. All of our service providers are subject to contract terms designed to ensure that these service providers process personal data only for the purposes of providing services to Stripe and in accordance with our commitments to Users and applicable data protection laws. Moreover, Stripe maintains and enforces a security program that addresses the management of security and the security controls employed by Stripe, which includes third party risk management. In addition, Stripe employees, agents, and contractors acknowledge their data security and privacy responsibilities under Stripe’s policies.

What data about End-Customers and their transactions is used by Radar and what data does Stripe share with its Radar Business Users?

When processing payments, it’s valuable to Stripe, Business Users and End-Customers to enable legitimate transactions while also trying to prevent fraudulent transactions, making online purchases safer for everyone involved. Radar helps detect potentially fraudulent transactions for Stripe’s Business Users (i.e., merchants) through machine learning and other techniques. To do this, Radar leverages data collected across our Services.

Business Users can use Radar to leverage a transaction “score” or transaction “level” calculated by Stripe and implement rules determined by the Business User that will allow, block, or flag transactions for additional review based on an assessment of the likelihood that the transaction is legitimate. Business Users can use Radar as one of multiple inputs in making decisions with respect to the potential for fraud in a transaction.

Radar uses data collected about the End Customer from various sources, including payments transaction data, advanced fraud detection data, IP address and physical address information. Radar uses this data to establish the likelihood that the payment method offered by the End Customer for a transaction is truly authorized for that transaction.

Stripe may share with the Business User certain information relevant to fraud detection, including:

• a transaction score or level that assesses the likelihood of the transaction becoming a fraudulent charge-back,
• risk insights for that transaction,
• related payments made by the End-Customer to the Business User,
• other transaction data related to that End-Customer’s transaction with that Business User (e.g., cardholder name, card information, and the payment amount and date),
• device and browser information for the device used to make the transaction with that Business User, and
• aggregated benchmarks.

As noted in Stripe’s Privacy Policy, Stripe does not sell personal data.

As a Business User, what notice do I provide to my End Customers about Stripe?

Under the terms of our agreements, Business Users are required to provide all necessary notices and obtain all necessary rights and consents from their End Customers to enable Stripe to lawfully collect, use, retain and disclose the Personal Data as part of the Stripe Services. Business Users, as data controllers, are responsible for the contents of their privacy notice and cookie banner. As an example, here is a paragraph that you can consider adding to your privacy notice (if you don’t already have such a disclosure):

We use Stripe for payment, analytics, and other business services. Stripe collects and processes personal data, including identifying information about the devices that connect to its services. Stripe uses this information to operate and improve the services it provides to us, including for fraud detection and prevention. You can learn more about Stripe and its processing activities via privacy policy at https://stripe.com/privacy.

Please be aware that the disclosure above is for illustrative purposes only and is not legal advice. Please talk to your legal advisor to understand how to comply with your obligations under applicable law.

To comply with our transparency obligations, we explain how our cookies are used in our Cookie Policy and our Cookies Settings Dashboard sets out our list of cookies. We remind our Business Users to review the cookies placed on their website and to update their cookie banners accordingly.

Stripe Legal Bases Tables

What legal basis does Stripe rely on to process personal data as a data controller?

We rely upon a number of legal grounds to enable our use of your Personal Data. In short, we use Personal Data to facilitate the business relationships we have with our Business Users and End Users, to comply with our financial regulatory and other legal obligations, and to pursue our legitimate business interests. We also use Personal Data to complete transactions and to provide payment-related services to our Business Users.

Our table below provides a detailed overview of why and how we use your Personal Data.

For the purposes of the General Data Protection Regulation, we rely upon a number of legal bases to enable our processing of your Personal Data.

End Users

When you directly use an End User Service (such as when you sign up for Link, or make a payment to Stripe Climate in your personal capacity), for your personal use, we refer to you as an “End User.”

End Customers

When you do business with, or otherwise transact with, a Business User (typically a merchant using Stripe Checkout, e.g. when you buy a pair of shoes from a merchant that uses Stripe for payment processing) but are not directly doing business with Stripe, we refer to you as an “End Customer.”

Representatives

When you are acting on behalf of an existing or potential Business User (e.g. you are a founder of a company, or administering an account for a merchant who is a Business User), we refer to you as a “Representative.”

Visitors

When you visit a Site without being logged into a Stripe account or otherwise communicate with Stripe, we refer to you as a “Visitor.” (e.g. you send Stripe a message asking for more information because you are considering being a user of our products).

Data Processing Agreement

What is a Data Processing Agreement (DPA) and how can I get one with Stripe?

A Data Processing Agreement (“DPA”) is a contract between a data controller and a data processor that describes the roles and responsibilities of the parties when personal data is processed. Article 28 of the GDPR sets out a number of requirements that a DPA must satisfy in order to be compliant with European data privacy law. We have made a DPA available to Business Users. Please contact us or your account manager for more detail.

Information about Stripe Products

How do you implement Privacy by Design at Stripe?

Privacy by design aims at building privacy and data protection up front and into the design specifications and architecture of information and communication systems and technologies to facilitate compliance with privacy and data protection principles. We rely on our internal privacy team and a review process for any new product launch. We are dedicated at every level of product development —from engineering to product management—to making privacy a key consideration. This helps ensure that people can trust the Stripe products that they enjoy every day.

Stripe Identity

End Customers

If you have been asked to verify your identity or have verified your identity using Stripe Identity, please visit the support web pages here and here to learn more about our privacy practices for Stripe Identity. Alternatively, you can jump to the specific topics linked here:

• Understanding Stripe Identity
• Biometric verification
• Consent to use my identity information
• Security of my identity data
• What data is collected
• Identity data retention
• Stripe’s role in controlling and processing identity data
• How I delete my identity data

Business User That Requested Verification

If you are a Business User that is using or intends to use Stripe Identity, please visit the support web page here for additional guidance on what you can tell your users and here for additional guidance on privacy considerations for your business.

Stripe Connect At a Glance

Description

Stripe Connect is a payment software your third party platform provider (Platform) may use to enable you to receive Stripe services (including payment processing) and/or receive payouts.

Data Controller/ Data Processor

Stripe acts as both a data controller and data processor for the Platform. The Stripe entity that acts as data controller/ data processor for data processed in Europe is Stripe Payments Europe Limited (“SPEL”).

Personal Data

The personal data transmitted to Stripe usually involves first name, last name, address, identification number, e-mail address, IP address, telephone number, and other data necessary for payment processing.

Purpose

The transmission of the data is aimed at payment processing, ledger management, and fraud prevention. The Business User / Platform will transfer personal data to Stripe. The personal data exchanged between Stripe and the Business User / Platform may be transmitted to verification agencies, and Business User data may be shared with Platforms. This transmission is intended for the Platform to manage its ledger and for Stripe to conduct identity and risk checks.

Transfer

Stripe will pass on personal data to affiliates and service providers or sub-processors, if deemed necessary to carry out contractual obligations or for the data to be processed.

Privacy Policy

For full details please see the applicable Privacy Policy of Stripe.

I am a user with a Custom connected account. Does Stripe also collect information about my Custom connected account from a third party?

If you are a user with a Custom connected account, Stripe may collect additional information about your account to enable fraud detection and fulfill financial compliance requirements. These requirements for additional information come from our regulators or financial partners and are intended to prevent abuse of the financial system. Examples of missing data fields include your address, phone number, social security number, date of birth, employer identification number, or website URL. Stripe may leverage data we already have from one of your Stripe accounts or Stripe may fill in some of this information by receiving data from a third party. You may view the information that we are associating with your account and update or correct that information by contacting the platform or business that created your Stripe payment account. Please see Stripe’s Privacy Policy for additional information.

What responsibilities do Connect platforms with custom accounts have to allow their users to update or correct information associated with their accounts?

You, the Platform, are responsible for all interactions with your Custom accounts and for collecting all of the information needed to verify the Custom account-holders. Since Custom account holders cannot log into Stripe, it is up to you to build the user dashboard and communication channels. You are responsible for actioning any request by a user to update or correct their Stripe Custom account information.

I am a user with a Custom connected account. Will data collected from a third party be visible to my customers?

Card networks and issuers use statement descriptors to identify payments on a cardholder’s bank statement. Statement descriptors usually include information about the payment, such as the name and phone number of the seller. However, the exact information displayed is ultimately up to a cardholder’s bank. If Stripe updates your account’s business address, phone number, or email address, these fields may be displayed on the statement descriptor within the cardholder’s bank statement. However, the exact information displayed is ultimately up to the card network or the cardholder’s bank. If any information is incorrect, please reach out to the platform through which you receive charges to ensure you have provided them with the most accurate information about you and your business.

What are Stripe ACS, Transaction Authentication, and Behavioral Biometrics?

What is Stripe ACS?

Stripe ACS is Stripe’s transaction authentication solution for card issuers (e.g., banks). Stripe ACS helps card issuers to authenticate transactions of cardholders when they are making payments online using their cards.

What is behavioral biometrics?

Behavioral biometrics is an innovative technology that can be used for the purpose of preventing fraud and identifying legitimate transactions. Behavioral biometrics leverages a combination of personal data and device characteristics to distinguish between legitimate customers and fraudsters or bots.

How is behavioral biometrics data collected and used in Stripe ACS?

This processing is designed to verify a cardholder’s identity based on their behavioral biometric data which is modeled based on data collected during each authentication attempt.

This type of transaction authentication will typically observe interactions within a system or device to verify a cardholder’s identity for the purposes of authenticating online payments. The following elements may be processed during the authentication process:

• Length of text field inputs
• Location of mouse pointer
• Modifier key details (e.g., CTRL, SHIFT)
• Timing and location of mouse clicks
• Timing and location of touch events
• Timing between keystrokes
• Window scroll position

For the purpose of fraud risk mitigation, this processing involves use of a device identifier cookie (Ndcd, Device ID, DID) that aims to accurately analyze biometrics data observed on a specific device. This cookie facilitates device detection in order to enhance fraud detection and prevention as well as to identify suspicious devices or devices that are behaving abnormally. This is a first party, strictly necessary cookie that is active on the touch.tech and touchtechpayments.com domains, and has a duration of 12 months. For more information on how we use cookies, please see Stripe’s Cookie Policy.

Purpose of processing and Stripe’s role

Stripe may process biometric data relating to cardholders in order to assist card issuers to authenticate payment transactions. This is done as part of Stripe’s payment transaction authentication services provided to card issuers (including for the purposes of meeting Strong Customer Authentication requirements).

In providing these services to card issuers, Stripe acts as a data controller in relation to cardholder data. Please see Stripe’s Privacy Policy to learn more about our use of personal data.

As part of providing this authentication services to card issuers, Stripe engages with a third party provider, Mastercard, which also acts as a data controller. See Mastercard’s Privacy Notice for details on Mastercard’s processing activities in this context.

Customers rights and choices

Upon initiating a transaction, cardholders will have the option of providing their consent to processing their behavioral biometrics data as part of the transaction authentication flow. This will be presented to the cardholder during the checkout flow on the merchant’s website or app when authentication is requested from the card issuer. Cardholders will have the option to withdraw their consent during each subsequent transaction flow.

To withdraw consent outside of a transaction flow, you can email privacy-acs@stripe.com with the subject matter line “Stripe ACS - withdraw consent”. In your email to withdraw consent, please provide: (a) the first 6 digits of your card number as this enables Stripe to identify your issuing bank (please do not provide any digits other than the first 6 digits); and (b) the phone number (including the country code) registered with your bank account that is used for one-time passcodes.

We will action this withdrawal request as soon as possible after it is verified, but please note that this can take up to 10 working days as we may need to verify the request with your card issuer. You may also contact the card issuer in order for the issuer to implement this withdrawal of consent by engaging with Stripe.

To submit a request to exercise any of the other rights described in our Privacy Policy, you may contact Stripe at privacy-acs@stripe.com.

Promotional Emails Feature

For End Customers and prospective End Customers of our Business Users

What is the Promotional Emails feature?

Promotional Emails is a feature that gives Business Users who use “Stripe Checkout” services a new tool to enable sending email promotional content to their customers and prospective customers. When you visit a Business User’s checkout page (that is powered by Stripe Checkout services), the Promotional Email feature will enable Stripe to collect information about your preferences to receive promotional emails from that merchant.

Promotional email preferences are collected whether or not you complete the purchase or are just a prospective End Customer. “Prospective End Customer” means you visited a Business User’s site and expressed an intent to make a purchase by starting a purchase on the Business User’s checkout page, but did not complete that purchase during that session. To be a “prospective End Customer” for the promotional email feature, you also need to have started to input your contact information into the checkout form, and then not delete that information prior to the end of the session.

If you, prospective End Customer, indicate permission to receive news and personalized offers by virtue of the opt-in/opt-out checkbox on your Business User’s checkout form, the following personal data is provided to your Business User so that your Business User can contact you to remind you of the items you left in the checkout or to provide you news and personalized offers:

• Email (if provided by you).
• Items in your cart with that merchant (if any).

“Personalized offers” means promotional or marketing materials tailored to you, such as coupons or advertisements based on the items in your cart or (in some cases) your prior purchases from that Business User. Even if you opt-out of personalized offers by a Business User, if you do business with that Business User, they may still need to contact you in order to enable a purchase (e.g., for delivery or billing purposes) or in connection with customer support. Please see your Business User’s privacy policy for more information.

What is Stripe’s role (Data Processor/Controller) in the processing of my Personal Data?

For the Promotional Emails feature, Stripe acts as a data processor or service provider, meaning that Stripe is acting at the direction of the Business User that has implemented this Stripe provided feature. The Stripe entity that acts as a data processor for personal data is:

• Stripe Inc. in the United States.
• Stripe Payments Europe Limited outside of the United States, including Europe.

What Personal Data Is Stripe Collecting?

Stripe’s Privacy Policy describes in more detail the personal data that Stripe collects in connection with payment transactions.

What Personal Data is Shared by Stripe with the Business Users I use?

Whenever you complete a transaction on a Business User’s website that uses Stripe services, as a service provider to that Business User, Stripe will share your contact information with that Business User. Business Users use the information that Stripe provides in accordance with its own privacy policy, including in connection with your purchase. With the Promotional Emails feature:

With the Promotional Emails feature:

• If you complete a purchase with a Business User, in addition to the transaction-related information identified in our Privacy Policy (e.g., your contact and billing information and the details of your transaction), Stripe will also share with your Business User your personalized offers and news preferences as determined by the opt-in/opt-out checkbox from your checkout form.
• If you are a prospective End Customer (you start a purchase with your Business User on their checkout form but do not complete that purchase), the personal data that we share with your Business User depends on the following:
  • If you have not inputted any personal data into your Business User’s checkout form, then we will not share any personal data with that Business User.
  • If you have inputted personal data into your Business User’s checkout form:
    • If the checkbox for receiving news and personalized offers is not enabled when you leave your Business User’s checkout session, we will not share any of that personal data.
    • If the checkbox for receiving news and personalized offers is enabled when you leave your Business User’s checkout session, we will share the following information with that Business User:
      • Email (if provided by you).
      • Items in your cart with that merchant (if any).

End Customers and prospective End customers should always review the privacy policy or notice of the Business Users they visit and do business with for information about the Business User’s data collection practices and purposes outside of this Stripe feature.

Does Stripe share my personal data with other Business Users?

No. Stripe does not share personal data collected in connection with purchases (or attempted purchases) from one Business User’s checkout with another Business User. Please see our Privacy Policy to learn more about our practices.

How do I stop promotional emails from a merchant?

Any offers or promotional emails that you receive as a result of a Business User’s use of the Promotional Emails feature are sent by Business Users (or others identified in the message), and not by Stripe. I If you do not find value in receiving these emails, please contact the Business User you are receiving the messages from. Stripe requires that Business Users that choose to implement the Promotional Email feature also provide the option to unsubscribe or opt-out of receiving further promotional messages. It would be a breach of Stripe’s terms of service for a Business User to not promptly comply with opt-out requests.

How Does the Data Collection and Transfer Work?

The Promotional Email feature does not use cookies or track you across Business Users. Information collected from the Business User’s checkout page is transferred only to the Business User via API calls or webhooks. Webhooks are a way for Stripe to send the information to the Business User automatically upon their request. Your information provided at checkout is encrypted in transit using HTTPS and TLS. See Security at Stripe for more information.

How do I stop the sale of my personal data in connection with this feature?

Stripe does not sell your personal data. See our Privacy Policy for more information. The Promotional Emails feature is not the sale of personal data. Rather, Stripe acts as a processor (or service provider) to Business Users for the Promotional Email feature. Please contact your Business User to learn about their personal data practices and how you can exercise rights to stop the sale or processing of personal data provided under applicable law and/or their privacy policy.

Stripe requires that Business Users that choose to implement the Promotional Email feature also provide the option to unsubscribe or opt-out of receiving further promotional messages. It would be a breach of Stripe’s terms of service for a Business User to not promptly comply with opt-out requests.

For Business Users

How to Use this Service as a Business User

If you are a business that is using or intends to use Stripe’s Promotional Emails feature, please visit the support webpage for tips and guidance on information to share with your End Customers and prospective End Customers regarding privacy considerations in connection with the Promotional Emails feature for your business.

Stripe Delegated Authentication

Cardholders

You may be given the option to enable on-device biometric verification and provide your consent for Stripe to store your payment method details for future transactions that use the same card. Please visit our support site to learn more about our privacy practices for Stripe Delegated Authentication. Alternatively, you can jump to a specific topic here:

• Why does the cardholder see Stripe when asked to authenticate a payment?
• What is Stripe Delegated Authentication?
• How is personal data used in Stripe Delegated Authentication?
• How can cardholders provide and withdraw their consent for the storage of their payment method details?

Link

We offer you the opportunity to store your payment methods with us so that you can conveniently use it across certain merchants who are our Business Users – we call this “Link” (formerly known as “Remember Me”). When you choose to use Link, you agree to let us store your payment method so that you can more readily make purchases through Link with Business Users of our payment processing Business Services (e.g., name, card number, cvc, and expiration date). We will also collect other Transaction Data, including billing address, shipping address, email and phone number. Your payment method data is secured using PCI-DSS standards.

Should you not have used Link and receive an SMS in error due to an inaccurate number being inserted at the authentication flow stage you can opt out here and your personal data will be deleted.

Stripe Capital

Stripe Capital provides Business Users with fast, flexible financing so businesses can manage cash flows and invest in growth. Depending on your business’s corporate structure, eligible Business Users may apply for one of two Stripe Capital products: a loan or a merchant cash advance (“MCA”).

What information does Stripe process for Stripe Capital?

We use existing data linked to your Stripe Account to evaluate your business’s eligibility for Stripe Capital. The following information may be considered prior to the offer of a loan or a MCA in order to determine eligibility, including:

• Payment processing volume
• Payment processing growth
• Chargeback rate
• Customer base
• Duration of relationship with Stripe

Analysis of this information helps us to make automated eligibility decisions and such information is analysed using machine learning. Where Stripe is satisfied that a Business User meets particular criteria, we will send the Business User an email and dashboard notification notifying them of their business’s eligibility for potential financing.

Once you have received a financing offer and submitted an application to receive your financing, we will use this above listed information to verify your business’s eligibility based on automated processing and where your application is approved, to disburse the loan or the MCA to you.

The legal basis for using your information

We will use your data where its use is in accordance with our legitimate business interests. Automated analysis of our Business User’s information helps us to manage our business for our legitimate interests. It allows us to:

• Verify the identity of our Business Users in order to comply with fraud monitoring, prevention and detection obligations, applicable laws associated with the identification and reporting of illegal and illicit activity, such as AML (Anti-Money Laundering) and KYC (Know-Your-Customer) obligations, and financial reporting obligations.
• Assess the level of financial risk to us and to Business Users involved in offering Business Users a loan or MCA.
• Enhance our learning models to allow us to better tailor our loans or MCAs to, and decrease the risk to, you and other Business Users.

We will also process your data where it is necessary for a loan agreement that you have entered into or because you have submitted an application to receive funding so that you can enter into a loan agreement with us.

We may send you email marketing communications about Stripe Capital offers, provided we do so in accordance with applicable law, including any consent requirements.

Who does Stripe share information with?

Stripe does not share any Personal Data collected for Stripe Capital related to Business Users in the UK. In the future, Stripe may share your loan agreement data with third parties who purchase the right to receive repayments on your loan or MCA.

What is Stripe’s role?

Stripe, Inc., or a wholly-owned subsidiary of Stripe, is the controller of your data.

For Business Users located in the UK, the joint controllers of your data are Stripe Payments Europe, Limited. (“SPEL”) and Stripe Capital Europe Limited, Ltd. (“SCEL”). The loan or MCA provided under the loan agreement is provided by SCEL.

How do I exercise my rights?

Depending on your location and subject to applicable law, you may have the right to object to Stripe using automated decision making processing. If you wish to exercise any rights under applicable privacy laws for data related to Stripe Capital, please contact us.

Linked Financial Accounts

If you are an End Customer who has been asked to link your financial account using Stripe, please visit the support webpage here to learn more about our privacy practices. Or you can jump to the specific topics linked here:

• Linking my financial account and consent
• Data collected, stored, and shared from my linked account
• How Stripe accesses data from my linked account
• Relationship between Stripe and its service providers
• Data security
• Who can access data from my linked account and for what purposes
• Who will obtain my login credentials
• Requesting disconnection or data deletion
• Correcting my financial account information

Are there instances when Stripe receives non-Stripe transaction history?

Yes. For example, Stripe enables the Business User to import non-Stripe data through the Stripe Dashboard to consolidate their revenue data in one place. Learn more. Separately, Stripe may also obtain your account transactions from your financial account with your consent. Learn more.

Data Protection Officer

Does Stripe have a Data Protection Officer (DPO)?

Yes, Stripe has appointed a Data Protection Officer (“DPO”), who can and they can be reached via email.

International Data Transfers

The detail below is provided for informational purposes. It is not intended to provide legal advice. Stripe urges Business Users to consult with counsel to familiarize themselves with the requirements that govern their specific situations.

How is Stripe dealing with international data transfers?

On 4 June 2021, the European Commission adopted a new set of Standard Contractual Clauses (“SCCs”) for cross-border data transfers. SCCs are a transfer mechanism (in the form of a legal contract) used by Stripe to provide a legal mechanism to transfer EU personal data outside of the EEA/UK. These are required under EU data protection law (known as the GDPR) and are incorporated into our agreements.

These modernised SCCs cover data transfers from controllers or processors in the EU/EEA (or otherwise subject to the GDPR) to controllers or processors established outside the EU/EEA (and not subject to the GDPR) and replace the three sets of SCCs that were adopted under the previous Data Protection Directive 95/46.

Stripe continues to have appropriate safeguards and compliance measures to ensure an adequate level of protection of personal data transferred outside the UK, EEA and Switzerland. Stripe’s measures include the updated EU Commission’s SCCs to accommodate international data transfers.

Stripe respects the privacy of everyone that engages with our products and services, and we are committed to being transparent about our privacy processes and policies.

To learn more about our commitment to privacy and data security, please see our Privacy Policy, the Stripe Privacy Center, and the Stripe Security Center.

We also want to highlight some of our supplementary measures to protect our Business Users’ data from unauthorized access.

Stripe employs security controls and maintains and enforces a security program that addresses the management of security. We also perform risk assessments and implement and maintain controls for risk identification, analysis, monitoring, reporting, and corrective action. Stripe maintains and enforces an asset management program that appropriately classifies and controls hardware and software assets throughout their life cycle. In addition, Stripe employees, agents, and contractors acknowledge their data security and privacy responsibilities under Stripe’s policies.

Stripe applies technical and organizational measures that include the following:

• Physical access control to prevent unauthorized persons from gaining access to the data processing systems available at premises and facilities (including databases, application servers, and related hardware), where Personal Data are processed.
• Virtual access control to prevent data processing systems from being used by unauthorized persons.
• Data access control to ensure that persons entitled to use a data processing system gain access only to such Personal Data in accordance with their access rights, and that Personal Data cannot be read, copied, modified or deleted without authorization.
• Disclosure control to ensure that Personal Data cannot be read, copied, modified or deleted without authorization during electronic transmission, transport or storage on storage media (manual or electronic), and that it can be verified to which companies or other legal entities Personal Data are disclosed.
• Entry control to audit whether data have been entered, changed or removed (deleted), and by whom, from data processing systems.
• Availability control to ensure that Personal Data are protected against accidental destruction or loss (physical/logical).
• Separation control to ensure that Personal Data collected for different purposes can be processed separately.

By default, Stripe encrypts data at rest and data in transit. We further protect your data with tools like audit logs, access management policies and certifications as described on our Payments page in the section “Security and compliance at the core”. Security controls implemented at Stripe include TLS 1.2 configuration of endpoints for data in transit, TLS and/or SSL encryption for HTTPS and regular testing of infrastructure components. Two-step authentication is available for an extra layer of security at Dashboard login.

We no longer rely on the Privacy Shield as a transfer mechanism for data transfers given EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield are no longer valid as a result of the Schrems II decision issued by the European Court of Justice on July 16, 2020. We do continue to commit to the principles of the Privacy Shield Framework as it can still provide privacy protections to Business Users.

We get requests for access to data from law enforcement, and we review each request with the goal of responding with the minimum amount of required information in response to legitimate, legally mandated requests. We are committed to ensuring that our Business Users’ data can continue to flow freely between the EU and the U.S., and we will continue to partner with regulators, industry groups and similarly situated companies to make sure our Business Users’ needs are met.

If you have any questions, please contact us.

How do the European Commission’s new Standard Contractual Clauses impact my organization?

Standard Contractual Clauses (“SCCs”) are legal contracts entered into between parties that are transferring EEA personal data outside of the EEA. At present Stripe relies on the existing SCCs for transfers of EEA data in our services. We have updated our agreements to implement the modernised SCCs (where applicable).

How to get a copy of the SCCs?

We can provide more information about the appropriate or suitable safeguards that we have in place, such as a copy of the SCCs on request.

If you are a Business User, we offer the modernised SCCs published in 2021 (“2021 SCCs”) for cross-border transfers outside of the EEA and Switzerland. The older versions of the SCCs will continue to apply to transfers of personal data from the UK. We will continue to monitor regulatory requirements and guidance from the UK Information Commissioner’s Office. If you have signed an older version of the SCCs, these will remain valid until 27 December, 2022. If you would like to sign the 2021 SCCs, you can reach out to us at any time.

Please contact us or your account manager for more information.

Your Rights and Choices

How do I exercise my data protection rights?

Depending on your location and subject to applicable law, you may have the followings rights:

• Right to access
• Right of rectification
• Right to data portability
• Right to restrict processing
• Right to object to processing
• Right to withdraw consent (where it is relied upon)
• Right to erasure/deletion
• Right to opt-out of receiving electronic communications from us
• Right to non-discrimination for exercising your CCPA rights
• Right to opt-out from a sale (as defined by the CCPA)

Please read this section to find out more about specific rights. To submit a request to exercise any of the rights described above, please reach out to us by email, or via our form or by physical addresses listed in Contact Us.

You have the right to complain to your local data protection authority if you are unhappy with our privacy practices.

How do I access my data?

If you are a Business User or Representative, you may login in to the Stripe Dashboard to view personal information shared with Stripe.

If you are the End Customer of a Business User that uses Stripe services, the Business User would be the correct party to respond to a data subject access request related to your transactional information.

Depending on your location and subject to applicable law, you may have the right to request confirmation of whether Stripe processes Personal Data relating to you, and if so, to request a copy of that Personal Data. If you are an End User or otherwise have a direct relationship with us, you may submit your access request by email, or through our form. Please note that we may need to verify your identity and your relationship with us before we can proceed with your request.

How do I unsubscribe from marketing emails?

If you are a Business User or Visitor, you may unsubscribe from Stripe marketing emails here. If you have any questions about how to opt-out of Stripe marketing communications, please contact us here.

Can I turn off tracking and advanced fraud signals?

Your web browser may allow you to manage your cookie preferences, including deleting or disabling Stripe cookies. If you choose to disable cookies, keep in mind that some features of our Site or Services may not operate as intended. Disabling cookies will not disable the collection of advanced fraud signals, which we use to prevent fraud on Stripe. The collection of this data is controlled by the Business User that integrated with Stripe. If a Business User seeks to disable this data collection, they can find instructions to do so through Stripe’s documentation. You can take a look at the help section of your web browser or follow the links below to understand your options for disabling cookies.

• Google Chrome
• Microsoft Internet Explorer
• Microsoft Edge
• Safari
• Firefox
• Opera

You can learn more about how businesses can disable collection of advanced fraud signals in our documentation for disabling advanced fraud detection.

How do I delete my account?

You can close your Stripe account from the Settings page on the Dashboard. You can read more about that on our support page: Close a Stripe account.

Please be aware that we will delete some, but not all, of the information that we hold, for the reasons explained below.

As a provider of payment services, Stripe is required to comply with many regulations, including anti-terrorism and anti-money laundering laws. These regulations and laws may require Stripe to retain transactional records associated with Business Users for a prescribed period of time after the close of the business relationship. You can read more about our underwriting obligations in our Privacy Policy.

How do I delete my Custom Connect account?

If you have a Custom Connect account, your account is managed by a Platform / Business User. They are the party responsible for managing payments for you and responding to your query; therefore we recommend reaching out to them for assistance.

How do I delete my Express Connect account?

If you have an Express Connect account, your account is managed by a Platform / Business User. They are the party responsible for managing payments for you and responding to your query; therefore we recommend reaching out to them for assistance.

How long will Stripe keep my data for?

Stripe keeps Personal Data for as long as Stripe reasonably needs to for the purposes listed here.

When determining the relevant retention periods, we will consider various criteria such as your location, the nature of our relationship with you, the types of products or services being offered or provided to you, the nature and sensitivity of your Personal Data, the mandatory retention periods provided by law or statute of limitations and any overriding legitimate grounds for continuing to retain the Personal Data (such as defending our rights in court, enforcing our agreements, detecting fraud or complying with valid legal process requests from courts or competent authorities).

For most jurisdictions, Stripe will generally keep Personal Data related to Business Users for a period of five or more years from the end of the business relationship with you, or the date of the last transaction, whichever is later.

Cookies & Other Technology

How does Stripe use cookies?

We use cookies to (1) ensure that our services function properly, (2) prevent and detect fraud and violations of our terms of service, (3) understand how visitors use and engage with our website and (4) analyze and improve our services. Depending on your relationship with Stripe and the domain you are visiting, different cookies apply. For instance some cookies are set on the public Stripe domain, some on the Stripe Dashboard when you are logged in as a Stripe user, and some on the payment page available to end users who make payments and use the services Stripe provides.

Cookies play an important role in helping Stripe provide personal, effective and safe services. Please be mindful that we change the cookies periodically as we improve or add to our services. For more information, please see our Cookie Policy.

What is Stripe.js?

Stripe.js (and its iOS and Android SDK counterparts) is a JavaScript library that businesses use to integrate Stripe and accept online payments. Once Stripe.js is added to a site or mobile app, fraud signals are used to differentiate legitimate behavior from fraudulent behavior.

For example, fraudsters and bots are less likely to spend time on different pages, which we’re able to detect and use as a signal in stopping fraud.

When you visit a site that uses Stripe, this fraud prevention could appear in a privacy report or tracker list in your web browser.

While you might see Stripe in a tracker list, we’re not building an individual tracking profile on you. Stripe doesn’t—and won’t—share or sell this data to advertisers.This data is securely exchanged between the following Stripe-controlled hosts:

• js.stripe.com
• m.stripe.network
• m.stripe.com
• q.stripe.com

The data collected by these endpoints is designed to be secure and to not leave Stripe infrastructure. Access to this data is tightly controlled, and restricted to a small number of Stripe employees working on fraud prevention and security (and permissions are regularly reviewed). You can read more about this in our Privacy Policy.

What are advanced fraud signals?

Stripe’s advanced fraud detection looks at signals about device characteristics and user activity indicators that help distinguish between legitimate and fraudulent transactions. These signals are highly indicative of fraud and power Stripe’s fraud prevention systems, such as Radar. The signals are securely transmitted to Stripe’s backend by periodically making requests to the m.stripe.com endpoint.

You can learn more in our documentation for advanced fraud detection.

Why are advanced fraud signals not ad tracking?

Stripe only uses these advanced fraud detection signals to enable secure payments and prevent fraud. We don’t use this data to build individual profiles or share or sell it to third-party advertisers.

You can read more about how we use this data in our Privacy Policy.

How does Stripe remember payment method details for Link?

Link (formerly known as “Remember Me”) lets end users save and reuse their payment information for faster checkout at thousands of online businesses. When an end user makes a purchase via a Business User (i.e., merchant) that enables Link, the end user can ask Stripe to remember their payment method details, such as credit and debit card details. If an individual chooses to be remembered, Stripe will remember the end user’s email address, phone number and payment method details for future Link transactions.

Whether the payment method details for future transactions are remembered across multiple Stripe Business Users, or only for that one Business User from which the end user signed up for Link, will depend on whether the checkout was a Stripe Checkout, or the Business User’s own checkout page (see Elements). For Stripe Checkout, once the cookie is set, the end user may make “1-click” purchases using Link in Stripe Checkout, which means that Stripe will automatically populate the end user’s saved information into Stripe Checkout on their behalf, and use the information to complete the transaction faster. For Elements, if the end user signed up for Link via the Business User’s checkout page (where the Business User has set the cookie), Stripe is able to remember the end user and their payment method details to allow for faster payments for only that Business User’s domain.

If the end user enters their phone number or email address during a future Link transaction, Stripe will authenticate the end user by sending the end user a One Time Passcode (OTP), e.g. via an SMS message. If the end user correctly enters the OTP, Stripe or the Business User will set a cookie in the end user’s browser, indicating that the end user has been authenticated. If the end user does not enter the OTP, or elects to “log out” of their Link session then the cookie won’t remember the end user.

A cookie is only stored in a specific browser on a specific device. If an end user wishes to make 1-click purchases in a different browser or on a different device, they must go through the OTP authentication process for the new browser or device combination.

The cookie expires after 90 days, at which point in time it will be necessary for the end user to re-complete the OTP process. The end user may also proactively remove the cookie by clearing cookies in their browser or by selecting the “log out” option when this option is presented in Stripe Checkout or the Business User’s checkout.

If an end user no longer wishes for Stripe to remember their payment method details for future Stripe Checkout or Elements transactions, the end user may use the self-service deletion tool. Alternatively, the end user may also contact Stripe support to make this request.

The description above describes how an end user may control how their information is stored and used for Stripe Checkout or Elements transactions. However, this does not affect the other contexts in which Stripe may store and use end user information. In particular, Stripe may store and use such information as described elsewhere on this Privacy Center - including for purposes such as for advanced fraud detection.

Contact Us

Contact our Privacy team

If you have any outstanding privacy questions after reviewing the privacy policy, please don’t hesitate to reach out to us by email, or through our form.

If you’d like to send us physical mail, please send to:

Stripe, Inc.
354 Oyster Point Boulevard
South San Francisco, California, 94080, USA
Attention: Stripe Legal

Stripe Payments Europe Limited
1 Grand Canal Street Lower, Grand Canal Dock, Dublin, D02 H210, Ireland
Attention: Stripe Legal

Where can I learn more about Stripe’s security practices?

Visit our security page to learn more about Stripe’s security practices. You should contact us by email immediately if you become aware of any unauthorized use or any other breach of security regarding the Stripe services.